Administrative Policy
13 June 1994 External T.I. 5-941205 -
4 October 1991 T.I. (Tax Window, No. 10, p. 19, ¶1496)
9 May 1991 T.I. (Tax Window, No. 3, p. 13, ¶1252)
ATR-39 (11 March 1991) "Deferred Salary Leave Plan"
2 October 89 T.I. (March 1990 Access Letter, ¶1163)
18 October 89 Meeting with Quebec Accountants, Q.11 (April 90 Access Letter, ¶1166)
18 October 89 Meeting with Quebec Accountants, Q.12 (April 90 Access Letter, ¶1166)
Articles
Greville, "Sabbatical Plan Constitutes Effective Method of Deferring Compensation", Taxation of Executive Compensation and Retirement, December 1989/January 1990.
Paragraph 6801(a)
Administrative Policy
19 December 2016 External T.I. 2016-0643191E5 F - Deferred Salary Leave Plan (DSLP)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) | salary advance arrangement results in recognition when advances made rather than when earned | 123 |
| Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(n) | deduction where “repayment” of advances made during employee leave | 211 |
2013 Ruling 2012-0451771R3 - Deferred Salary Leave Plan (DSLP) - ITR 6801(a)
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8 June 1995 T.I. 950741 (C.T.O. "Conditions re DEF SAL Leave Plan")
5 June 1995 T.I. 950581 (C.T.O. "Deferred Salary Relief Plan 6801(a)")
23 June 1993 T.I. (Tax Window, No. 32, p. 22, ¶2627)
13 January 1992 Memorandum (Tax Window, No. 15, p. 21, ¶1694)
Subparagraph 6801(a)(i)
Administrative Policy
29 May 2014 External T.I. 2014-0520851E5 F - Deferred Salary Leave Plan
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 6801 - Paragraph 6801(a) - Subparagraph 6801(a)(iv) - Clause 6801(a)(iv)(B) | no requirement for employer to provide a return on the deferred amounts | 184 |
Subparagraph 6801(1)(a)(iii)
Administrative Policy
23 January 2014 External T.I. 2013-0515721E5 F - Deferred Salary Leave Plan
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 6801 - Paragraph 6801(a) - Subparagraph 6801(1)(a)(v) | full-time employee cannot return on a part-time basis | 142 |
Subparagraph 6801(a)(iv)
Clause 6801(a)(iv)(B)
Administrative Policy
29 May 2014 External T.I. 2014-0520851E5 F - Deferred Salary Leave Plan
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 6801 - Paragraph 6801(a) - Subparagraph 6801(a)(i) | terms cannot provide for voluntary withdrawal of employee except where hardship | 166 |
Subparagraph 6801(1)(a)(v)
Administrative Policy
23 January 2014 External T.I. 2013-0515721E5 F - Deferred Salary Leave Plan
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 6801 - Paragraph 6801(a) - Subparagraph 6801(1)(a)(iii) | can have a salary deferral period, then leave, then payback period | 181 |
Paragraph 6801(d)
Administrative Policy
6 February 2019 Internal T.I. 2018-0762101I7 - Ruling request - DSU plan and EPSP
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 144 - Subsection 144(3) | proposed use of EPSP trust to produce equivalent of CCPC stock option plan was abusive | 520 |
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | use of EPSP trust to synthetically create the equivalent of a s. 110(1)(d.1) stock option plan would be a s. 245(4) abuse | 419 |
24 November 2015 CTF Roundtable Q. 2, 2015-0610801C6 - Salary Deferral Arrangements
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Salary Deferral Arrangements - Paragraph (k) | conversions of RSUs to DSUs no longer permitted except for grandfathered units | 237 |
29 April 2015 External T.I. 2015-0565181E5 - Amendment to DSU plan
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(11) | termination of Plan contrary to DSU rules triggered retroactive application of SDA rules | 204 |
10 April 2015 External T.I. 2014-0535951E5 - Election under DSU Plan
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2014 Ruling 2012-0457101R3 - Proposed amendments to a Deferred Share Unit Plan
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2012 Ruling 2011-0418571R3 - Amendment to 6801(d) Plan
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | amendment to add stock settlement alternative | 82 |
2010 Ruling 2010-0376531R3 - Plan with DSUs and 3-year bonus deferral PSUs
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2010 Ruling 2010-0353121R3 - Deferred Share Unit Plan
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2004 Miscellaneous 2004-0072041R3 - Deferred Shares Unit
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Articles
Anu Nijhawan, "Canada-U.S. Cross-border Deferred Share Unit Plans – Trips and Traps", Taxation of Executive Compensation and Retirement, Federated Press, Volume 24 Number 01 July/August 2012, p. 1559.
Jessica Bullock, "Recent Administrative Positions of the Canada Revenue Agency Regarding Deferred Share Unit Arrangements", Taxation of Executive Compensation and Retirement, Vol. XV, No. 3, 2011, p. 946.
Subparagraph 6801(1)(d)(i)
Administrative Policy
21 November 2016 Internal T.I. 2016-0641961I7 F - DSU Plan
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(11) | recognition in income of full value of deferred units issued under offside plan | 183 |